Política de Privacidad

1. Our Commitment to Privacy

Creative Mindset Productions (CMP) is committed to protecting the privacy and personal information of scholars and other users who participate in programs delivered through schools, parks and recreation centers, and other youth organizations.

This Privacy Policy explains how information may be handled through CMP technology, applications, games, digital platforms, and related services. It also explains the distinction between CMP’s technology responsibilities and the program recordkeeping responsibilities of STEAM Your Dreams (SYD).

2. Who Is Responsible for Information?

CMP develops and supports technology and digital experiences used in SYD programming. CMP may access limited information when necessary to build, operate, maintain, troubleshoot, or secure a service.

SYD manages its educational programming and maintains detailed program records about participating scholars. These records may include dates of birth and other information required for program administration and educational activities. Some information is maintained in STEAM IQ and SYD’s program database.

CMP does not automatically maintain or control all detailed scholar records held by SYD. Responsibility for a particular record depends on which organization collects, maintains, or controls it.

3. Types of Information

Depending on the service and program, information may include:

• Player IDs, usernames, or avatars.
• Gameplay scores, results, and participation records.
• Account or program identifiers.
• Technical information needed to operate, maintain, and troubleshoot a service.
• Information supplied by an authorized school, parks and recreation center, or other youth organization.
• Additional scholar information maintained by SYD for authorized program purposes.

The information collected varies by service. CMP and SYD should not collect more information than reasonably necessary for the relevant purpose.

4. How Information Is Used

Information may be used to:

• Deliver educational programming and digital activities.
• Operate games, competitions, leaderboards, and player accounts.
• Track participation and gameplay results.
• Provide technical support and maintain system reliability.
• Evaluate program engagement and outcomes.
• Respond to authorized requests from parents, guardians, schools, and youth organizations.
• Meet legal, contractual, safety, and recordkeeping obligations.

Personal information must not be sold or used for unrelated advertising or commercial profiling of scholars.

5. Protecting Scholar Identity in XR Sports Manager

XR Sports Manager is designed to use player IDs, usernames, or avatars rather than displaying the full names of scholars under 18 on public or shared leaderboards.

Before a deployment, the relevant settings and displays should be checked to reduce the risk of exposing full names or other identifying information. A player ID or avatar may still be identifiable if it is linked to other information, so additional care is required when sharing results publicly.

Schools, parks and recreation centers, and other youth organizations should follow their applicable policies and permissions when displaying or sharing competition results.

6. How Information Is Shared

Information may be shared only when reasonably necessary and authorized for program delivery, technical support, reporting, safety, or legal compliance.

Depending on the circumstances, authorized recipients may include:

• CMP personnel who need access to support the technology.
• SYD personnel who administer programs and maintain scholar records.
• Authorized representatives of participating schools, parks and recreation centers, or other youth organizations.
• Service providers supporting an authorized technology function.
• Other recipients where disclosure is authorized or required by law.

Access should be limited to the information needed for the recipient’s role. CMP and SYD do not automatically have access to all records held by one another.

7. Third Party Games and Platforms

Some program activities may use independently operated video games, hosting services, leaderboard systems, or other digital platforms.

These providers may collect information under their own privacy policies and terms. CMP does not control every independent provider’s data practices. Before using an external service with scholars, the responsible organization should review its privacy policy, age restrictions, data collection practices, and consent requirements.

Where possible, program settings should minimize the disclosure of scholar names and other identifying information. If a third party service cannot meet the program’s privacy requirements, an alternative should be considered.

8. Security and Access Controls

CMP and SYD should restrict access to personal information to authorized personnel with a legitimate need. Appropriate safeguards may include access permissions, authentication, secure handling procedures, system monitoring, and measures to prevent unauthorized disclosure.

Safeguards depend on the systems and information controlled by each organization. No method of electronic storage or transmission can be guaranteed completely secure.

Anyone who suspects unauthorized access, loss, disclosure, or misuse should notify the appropriate organization promptly.

9. Parent, Guardian, School, and Youth Organization Requests

A parent or legal guardian may request information about a scholar where they have the legal authority to do so. An authorized representative of a school, parks and recreation center, or other youth organization may also submit a request within the scope of their authority.

Requests may concern:

• What information is maintained.
• Access to or correction of information.
• How information is used or shared.
• Whether information can be deleted.
• Questions about retention or privacy safeguards.

Requests will be reviewed according to applicable law, agreements, and the authority of the person submitting them. Identity and authority may need to be verified before information is provided, changed, or deleted.

10. How to Submit a Privacy Request

1. Email the appropriate contact listed below with the subject line “Privacy and Scholar Data Request.”
2. Briefly describe the request and identify the program or service involved. Do not send sensitive personal information in the initial email.
3. The receiving organization will determine whether the request concerns CMP technology or SYD program records. Requests concerning detailed SYD records may be referred to SYD.
4. The organization may request reasonable verification of identity and authority and will provide instructions for securely supplying any additional information required.
5. The responsible organization will review the request and respond in accordance with applicable legal requirements and relevant agreements.

As an internal service goal, CMP and SYD should aim to acknowledge requests within five business days where practicable. This is a proposed service standard, not a statement of a statutory deadline. Applicable legal deadlines take precedence.

11. Retention and Deletion

Information should be retained only for as long as reasonably necessary for its stated purpose, subject to legal requirements, contractual obligations, program administration, and legitimate recordkeeping needs.

Requests to delete information will be evaluated by the organization responsible for the record. Information may be retained when required by law or where a legitimate obligation requires it. Where deletion is approved, the responsible organization should confirm completion through its established process.

12. Children’s Privacy and Applicable Laws

Programs serving children and teens require particular care when collecting, using, and sharing personal information.

Depending on the service and circumstances, applicable requirements may include COPPA, state privacy laws, contractual protections, and education privacy requirements such as FERPA where applicable. These laws do not apply identically to every organization or program.

Where required, appropriate parental consent, school authorization, notice, access, correction, or deletion procedures must be followed. Participating organizations should coordinate with CMP and SYD to establish the appropriate process for each service.

13. Photographs, Video, and Audio

Photographs, recordings, and other media featuring scholars may be used only with appropriate authorization and in accordance with applicable law, organizational policies, and consent requirements.

Taking part in a program does not by itself mean that a scholar’s image, voice, name, or personal story may be used for public marketing. Organizations should confirm that appropriate permissions are in place before publishing such material.

14. Privacy Incidents

Suspected loss, unauthorized access, disclosure, or misuse of personal information should be reported promptly to the organization responsible for the relevant system or record.

CMP and SYD should coordinate when an incident affects systems or records involving both organizations. They should assess the incident, take appropriate steps to contain and address it, and make notifications where required by law or agreement.

15. Updates to This Policy

This Privacy Policy may be updated as technology, programming, information practices, or legal requirements change. The effective date will be revised when an updated policy is published. Material changes should be communicated through appropriate channels.

16. Contact Information

Please use “Privacy and Scholar Data Request” as the email subject. Do not include sensitive personal information in your initial message.

Creative Mindset Productions (CMP)

Email: rsm2@createmindset.com

STEAM Your Dreams (SYD)

Email: info@steamyourdreams.org